Part 5 of 6 in our series on the compliance lessons from the FIU Annual Review 2025.
The invoice is in your customer’s name, but the money comes from another company. That does not have to be suspicious. A parent company may, for example, pay on behalf of a subsidiary. Yet the FIU Annual Review 2025 shows why third-party payments deserve more attention.
In one analysis of third-party payments to Dutch companies, 2,000 transactions were declared suspicious, with a combined value of €300 million. The Belgian Financial Intelligence Processing Unit (CTIF-CFI) also warns against the misuse of third-party payments. Why should the payer also be part of your customer and transaction overview?
What are third-party payments?
In a third-party payment, a party other than the buyer pays for goods or services. There may be a logical explanation for this, such as a payment arrangement within a corporate group. Extra attention is needed when that relationship is unclear or the payment pattern does not fit the business relationship.
FIU-Nederland, for example, identified a company that received money from several hundred different payers across multiple European countries. The Belgian CTIF-CFI describes how professional money launderers use companies as financial intermediaries in international trade transactions. This conceals financial connections and makes money flows harder to trace.
The order itself may be entirely legitimate. A correct invoice and a received payment do not yet provide clarity about the origin of the money.
Interesting read: Perpetual KYC: why customer due diligence does not stop after onboarding
Why finance and compliance need each other
This is where a blind spot can easily arise. Compliance investigates the customer, credit management assesses the debtor risk, and finance sees that the invoice has been paid. But who checks whether the payer has a logical connection to the transaction?
It is precisely this information that needs to be brought together. Finance sees who transfers the money and knows the payment pattern. Compliance can investigate how the payer and the customer are connected. Together, they can assess whether a discrepancy calls for further investigation.
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When is it wise to ask further questions?
A third-party payment does not automatically have to be rejected. A practical assessment starts with three questions:
- Can the relationship be explained? Verify a stated parent-subsidiary relationship using corporate group information. For a financier or intermediary, ask for documentation that substantiates their role and the payment arrangement.
- Does the payer fit the transaction? Look at the business activities, the country of establishment and the size of the payment. A discrepancy is not in itself evidence of money laundering. However, a missing or contradictory explanation does require attention.
- Is there an unusual pattern? One explainable third-party payment presents a different picture from dozens of unknown payers for the same customer. Therefore, also examine payments in relation to one another and over time.
Up-to-date company and ownership data helps verify the payer’s identity and relationships. This data does not prove where the money for a specific payment comes from. Therefore, combine it with invoices, agreements and explanations from the parties involved.
Interesting to read:: Recognising a front company: key warning signs and checks
Make the payer part of your checks
The key lesson: a paid invoice does not automatically mean that the flow of money can be explained. Therefore, document who checks the payer, when additional information is needed and who decides on the next steps.
This makes a third-party payment a deliberate checkpoint within your order-to-cash process.
Would you like to better assess who is behind a payment? Talk to our compliance experts and discover how up-to-date company and ownership data can support you in doing so.
